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The Big Challenge in New EU Data Protection Law: Values

Years ago, the chief compliance officer at a large manufacturing concern told me his biggest struggle was this: how to build an effective ethics & compliance program across cultures that have fundamentally different values.

The fundamentally different culture in his mind—to nobody’s surprise here, I’m sure—was China. How can you convince the Chinese that favoritism in awarding contracts is against company ethics, when personal connections are of supreme social value in China? How can you convince the Chinese to self-report misconduct, when shame is an outcome far worse and more offensive than guilt?

I’ve always thought my CCO acquaintance raised an excellent point. I just never expected that U.S. companies would see that gap in fundamental values emerge in such an unexpected way as it has this week.

The fundamentally different cultural value, of course, is privacy. And the place that sees it so differently is Europe.